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SCC

Hodgkinson v. Simms (1994), 117 DLR (4th) 161, 95 D.T.C 5135, [1994] 3 SCR 377

Damages in contract follow the principles stated in connection with the equitable breach.  ... However, in my view, on the facts of this case, damages in contract follow the principles stated in connection with the equitable breach.  ... Simms billed Olma Bros. for the financial services he was performing in connection with these MURBs.  ...
TCC

Garron Family Trust v. The Queen, 2009 DTC 1568, 2009 TCC 450, aff'd sub nom St. Michael Trust Corp. v. The Queen, 2010 DTC 5189 [at 7361], 2010 FCA 309, aff'd sub nom Fundy Settlement v. Canada, 2012 SCC 14

Bowman played an important role in connection with the 1998 reorganization. ... Michael informed of anything in connection with these transactions except when it was necessary for agreements to be signed ... It does not matter that the Trusts have few connections with Barbados. ...
TCC

Club Intrawest v. The Queen, 2016 TCC 149, varied 2017 FCA 151

Bare Trust Agreement.-             Exhibit A-1, Table 6: “ the guidelines setting out the rules applicable to members in connection with the Intrawest program. ” (the Membership Guidelines)-             Exhibit A-1, Table 8: The document entitled Purchase and Membership Agreement which agreement was entered into by the Canadian Developer and a Canadian Resort Point Purchaser (the Canadian Purchase and Membership Agreement)-             Exhibit A-3: A document entitled Membership Certificate [18]         As noted in paragraph 13 of the PASF, the parties are satisfied that the documents at Exhibits A-1 and A-2 are materially representative of these documents for the period between 2002 and 2007. ... As noted in paragraph 21(a) of the PASF, the principal rights that a Member of the Appellant has in connection with the Intrawest Program are the following: (a)   the right to use resort points held by the member to reserve the use of the vacation homes in accordance with the Guidelines [the Membership Guidelines] as established by the developer [the Canadian Developer]. [116]    This is a contractual right. ... Section 10.3 of the master declaration states that Membership Costs “shall include but not be limited to:” (a)   The maintenance, repair, modification, alteration, redecoration, or replacement of any Resort Accommodation; (b)   The maintenance, repair, modification, alteration, redecoration, replacement, and rental of the Equipment; (c)    Insurance coverage; (d)   A capital contribution for reserves; (e)    Domestic services, including cleaning and maid service, the frequency which shall be determined from time to time by the Board, furnished to or on behalf of Members; (f)    Assessment levied against Resort Accommodations by a Project or association for a Project; and (g)   Any other costs incurred by the Club in connection with the maintenance, repair, replacement, restoration, redecoration, improvement, operation, and administration of the Resort Accommodations, or in connection with the operation or administration of the Club, which are directly attributable to the commitment of one (1) or more Resort Accommodations in accordance with the provisions [of the Master Declaration]. 29.     ...
FCTD

Elson v. Canada (Attorney General), 2017 FC 459

And, finally, the valid exercise of s 91(12) requires a connection to the fishery as a resource and the PIIFCAF Policy has no such connection (Fowler v The Queen, [1980] 2 S.C.R. 213; Northwest Falling Contractors Ltd v The Queen, [1980] 2 S.C.R. 292; Ward v Canada (Attorney General), 2002 SCC 17 at paras 20-24, 34-36, 41-49 (“ Ward ”)).   ... Put simply, the Federal Fisheries Power can only be exercised when there is a constitutionally valid connection to the subject matter of s. 92(12), being the fishery as a resource. ... I also do not accept the Applicant’s submission that the PIIFCAF Policy must have connection to fish stocks or conservation in order to be a valid exercise of s 91(12).  ...
FCTD

Gordon v. Canada, 2019 FC 853

Gordon and Deacur in connection with 28 of the 31 SR&ED claims that were referenced in the indictments.   ... Girard had a number of concerns in connection with the large SR&ED valuation submitted in the amount of $775,000.   ... [Exhibit P-26] [178]   The issue of a potential fraud in connection with the Signet Marketing Inc. ...
FCTD

Canada (National Revenue) v. Shopify Inc., 2025 FC 968

On this evidence, Justice McDonald found that the Minister had demonstrated a sufficient connection between the content of the requirement and its stated purpose (Helcim at para 27). ... The context for the purpose of the interpretation of a treaty shall comprise, in addition to the text, including its preamble and annexes: (a) any agreement relating to the treaty which was made between all the parties in connection with the conclusion of the treaty; (b) any instrument which was made by one or more parties in connection with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty. 3. ... Nor do they constitute “context for the purpose of the interpretation of [the] treaty,” insofar as an Explanatory Report is not an “agreement relating to the treaty which was made between all the parties in connection with the conclusion of the treaty,” nor an “instrument which was made by one or more parties in connection with the conclusion of the treaty and accepted by the other parties as an instrument related to the treaty” (see Article 31(2)). ...
FCA

Tonn v. The Queen, [1996] 1 CTC 205 (FCA)

. — “personal or living expenses” includes (a) the expenses of properties maintained by any person for the use or benefit of the taxpayer or any person connected with the taxpayer by blood relationship, marriage or adoption, and not maintained in connection with a business carried on for profit with a reasonable expectation of profit,... ... McDonnell as follows: The expression [reasonable expectation of profit] is found in the Income Tax Act in the extended definition of personal or living expenses, which includes the phrase “the expenses of properties...not maintained in connection with a business carried on with a reasonable expectation of profit”. ...
TCC

Landrus v. The Queen, 2008 DTC 3583, 2008 TCC 274, aff'd supra.

    [116]      In a paper presented at the 1995 Canadian Tax Foundation Conference entitled “ New Rules, Old Chestnuts, and Emerging Jurisprudence: The Stop-Loss Rules ”, at p. 34:1, Edward Heakes described the policy underlying those rules in the Act as follows:   Tax legislators have long recognized that, in order to prevent undue erosion of the tax base, special rules are needed to deal with the recognition, denial, or deferral of losses for tax purposes that might otherwise be recognized on transfers of property between persons having a degree of connection or relationship with each other. ... An important variation, for the purposes of this case is in the degree of connection or relationship required between the transferor and transferee ...
TCC

Wescast Industries Inc. v. The Queen, 2010 DTC 1364 [at at 4432], 2010 TCC 538

Bowey, and with another accounting firm, with a view to obtaining tax advice in relation to the appellant’s business, not only in connection with the joint venture, but on a comprehensive basis. ... The human resource costs related to the expatriate connection and the technology cost related to the access that they had to technology. ...
TCC

Bernick v. The Queen, 2003 DTC 839, 2003 TCC 433

Subsection 96(8) mandated the lower of cost or market in connection with a Canadian resident partner becoming a member of a foreign partnership. ...   [59]     I allow the appeal only in connection with the penalties imposed by CCRA, referring the matter back for reconsideration and reassessment on the basis that penalties are to be reduced to $100 each for 1992, 1993 and 1994. ...

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